Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.
Displaying 3061 - 3080 of 4604
Date
Rule
801.1(c)
9/2/99 Proposal in 9/1/99 letter discussed by MB, MV and RBS. Agreed to make repurchase of C by A non-reportable since we had already reviewed As purchase of B (which included C)and D's proposed...
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(23.83 KB)
Date
Rule
7A(c)(10); 801.12; 802.9
9/1/99 - Left phone mail for writer advising that the Premerger Office (MV also reviewed earlier letter) agreed with his conclusions except for last paragraph on page 3. In that paragraph, control of...
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(102.44 KB)
Date
Rule
802.2(d)
I agree that other than the miscellaneous equipment, all of these assets are exemptunder 802.2(d).
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(500 bytes)
Date
Rule
801.40, 802.50(b), 802.51(b) and 801.11(e)
See notes on attached draft. (Editors note: this letter was the final version of9009008 and 9909011. On 9909011, staff made some notes/edits which were incorporated into this final document).
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(104.04 KB)
Date
Rule
802.2(d); 802.4
(none)
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(76.91 KB)
Date
Rule
803.1(b)
8/27/99 (Reviewed letter with PS and MV) We concluded that a voluntary response to Item 7 does not make the response to Item 9 mandatory. Advised writer that response to item 7, disclosing similar...
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(43.18 KB)
Date
Rule
801.40; 801.10
Called (redacted) 8/26/99 – Facts are not clear. Called (redacted) 8/26/99 and discussed the issues (see notes) and clarification of the scenarios presented
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(73.82 KB)
Date
Rule
801.1(f)(3)
8/19/99 Called writer and advised that no filing was required. The IPO action by Company B, in the context of Items 1 through 6 above ? and particularly the points made on Items 1 and 5 ?, render this...
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(66.96 KB)
Date
Rule
802.2(g)
Note # 1 - The barn where boxing the fruits and vegetables is not a facility or processing plant. Called writer on August 19, 1999. The boxing of the fruits and vegetables in the barn is deemed as an...
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(45.02 KB)
Date
Rule
801.11(b)(c)(d)(e)
Note #1 - added subsection (d); OK; called writer 8/11/99
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(41.29 KB)
Date
Rule
801.1(c)(8)
8/10/99 - Advised writer that letter accurately reflected view of Premerger Office in transactions such as this.
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(63.35 KB)
Date
Rule
802.9
8/6/99 - Writer advises that observer might be asked by board “ how is services and supply agreement going?†Observer would respond on status of such agreement. Supply Company A (through observer...
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(57.05 KB)
Date
Rule
801.2(d)(2)
Agree - no filings required for secondary acquisitions. Dick Smith concurs
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(43.99 KB)
Date
Rule
801.(c)(9)
Agree that this is our current position. R. Smith concurs.
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(40.15 KB)
Date
Rule
801.1(f), 801.11(b), 801.12 (b)
Advised the caller that except in the situation where convertible v/s are held in conjunction with a contractual right to designate directors & the percentage of v/s that would be held upon conversion...
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Original Image File
(69.62 KB)
Date
Rule
7A(c)(2)
Comments in body of letter
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(47.36 KB)
Date
Rule
801.2(d)(2), 801.2(d)(2)(iii)
Agree - no filings required for secondary acquisitions.
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(78.51 KB)
Date
Rule
801.1(a)(2); 7A(c)(4)
7/29/99 Writer advised that both members appoint of Board. Advised writer that the private university must file for the acquisition of non-exempt assets from the nonprofit controlled by it and the...
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Original Image File
(47.85 KB)
Date
Rule
802.20
Called (redacted) 7/23/99 and left message. I concur with the conclusion exemptions noted. PS
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(53.28 KB)
Date
Rule
801.10(b)
: 7/20/99 Called writer and advised that, as here, you do have an acquisition price (or a reasonable proxy for an acquisition price, since buyer is not presently within the LLC) for the assets...
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Original Image File
(26.59 KB)
Displaying 3061 - 3080 of 4604